Lawyer Article

Published in the September 6, 2005 issue of Southeast Tech Wire.

On August 26, 2005, the FCC’s Enforcement Bureau extended to September 28, 2005 the deadline for interconnected VoIP providers to obtain affirmative acknowledgement from subscribers of E911 limitations.

To qualify for the extended moratorium on enforcement, a provider must have already filed an initial compliance report on or before the August 10, 2005 deadline already provided by the FCC.

In addition, providers must file with the FCC by September 1, 2005 and again by September 22, 2005 reports updating progress made since August 10. These update reports must contain the following information:

• An explanation of current compliance with the notice and warning sticker requirements if the provider did not notify and issue warning stickers or labels to 100%of its subscribers by the July 29, 2005 deadline;
• A quantification of the percentage of the provider’s subscribers that have submitted affirmative acknowledgements as of the date of the September 1 and September 22 reports, and an estimation of the percentage of subscribers from whom the provider does not expect to receive an acknowledgement by September 28, 2005;
• A detailed description of any and all actions the provider plans to take towards any of its subscribers that do not affirmatively acknowledge having received and understood the advisory; and,
• A detailed description of any and all plans to use a “soft” or “warm” disconnect (or similar) procedure for subscribers that fail to provide an affirmative acknowledgement by September 2005.

This memo and the public notice is attached in PDF format here.

If you have any questions or need assistance developing or filing your reports, please contact Mark Palchick (email; (202) 857-4411) or Howard Barr.